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ASBESTOS ABATEMENT GUIDELINES

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					                         ASBESTOS ABATEMENT GUIDELINES

1.0   PURPOSE

      The Asbestos Abatement Guidelines are intended foe use as the basis for specific project specifications
      used to describe the scope f work to be performed by GAC during an asbestos abatement operation.

2.0   SCOPE

      These Asbestos Abatement Guidelines apply to all GAC abatement operations.

3.0   POLICY

      The use of appropriate engineering controls will be the primary method used by GAC to reduce worker
      exposure to airborne asbestos fibers.

      These procedures, both general and specific, are intended as guidelines for asbestos abatement operations
      based upon local, state and federal regulations and a comprehensive review of each project Each point
      discussed may not always be applicable to every asbestos abatement project and in these cases, the
      procedures outlined in this Guidelines will, of course, vary with the project


      These Guidelines will only be in force as a contractual agreement where the Owner and GAC have

      indicated mutual acceptance by signature.


4.0   GENERAL AND ADMINISTRATIVE REQUIREMENTS

      4.1      Contract Documents

              4.1.1     Licenses and Permits: When required, GAC will be responsible foe obtaining all
                        necessary licenses ad permits pertaining to the removal and disposal of asbestos
                        containing materials.

               4.1.2    Site Visits: GAC will make a site visit to verify all dimensions and become familiar with
                        specific site conditions. Where access is not feasible, for safety or other reasons, and
                        understanding of the proposed scope will be indicated.

              4.1.3     Contract Changes: All change orders or variances to the asbestos control procedures
                        must be approved in writing by the Owner or the Owner’s representative.

               4.1.4    Request for Variances: Any request for variance must be approved in writing prior to
                        beginning any phase of the work covered by the variance.

               4.1.5   Contract Materials: GAC is responsible for the handling, storage and transportation of
                       all materials, both new and / or salvaged, until such time as the job is completed.
                    ASBESTOS ABATEMENT GUIDELINES

                4.1.6      Damage Reimbursement: The contract document will place responsibility for
                           replacement of repair of any damage to the Owner’s property caused by GAC , its
                           employees, or by any subcontractor under its employ.

               4.1.7       Subcontractors: All subcontractors employed by GAC will be required to comply with
                           each applicable provision of these Guidelines. Refer to section 6-1, Sub-contractor
                           Policy, in the GAC Corporate Safety Program.

                 4.1.8     Insurance: GAC will provide the Owner with proof of asbestos specific liability
                           insurance written in an “occurrence” type policy in the amount of one million
                           (1,000,000,000), as well as general liability insurance in the same amount. A certified
                           letter from NLR.AM insurance broker will provide appropriate verification of the
                           insurance carrier’s knowledge of GAC asbestos abatement business.

                4.1.9      Bonding: GAC will provide a 100 percent Treasury-type performance bond which will
                           be underwritten by a nationwide insurance company having a BEST rating of A-15.

                4.1.10     Waste Removal: Unless otherwise specified by the contract document, GAC will be
                           responsible for obtaining a waste disposal site in compliance with all applicable EPA,
                           state or local Regulations.

                4.1.11     Services and Equipment: Unless otherwise specified by the contract document, GAC
                           will furnish all labor, materials, services and equipment necessary to carry out the
                           abatement operations in accordance with OSHA Standards, EPA Guidelines and all
                           applicable state of local government regulations governing the job site.

                4.1.12     Fire and Emergency: GAC will develop a fire and emergency action plan for use in
                           connection with the asbestos abatement operation. Emergency procedures will have
                           priority over the abatement operations. Refer to section 4-0, Emergency Action Plans, in
                           the GAC Corporate Safety Program.

4.2   . Applicable Codes

        General applicability of Codes and Regulations. Except to the extent that more explicit, or more stringent
        requirements are written directly into these Guidelines, all applicable codes and regulations will have the
        same force and effect as if copies directly into these Guidelines.

        In order to comply with all local, state and federal requirements, copies of all required documents,
        including appropriate EPA Guidelines and OSHA Standards, will be maintained at the job site. Specific
        documents required for employee information will be posted in the Clean Room of the decontamination
        unit.
                         ASBESTOS ABATEMENT GUIDELINES

4.2.1   Federal Regulations: Those which govern asbestos abatement work or hauling and disposal of
        asbestos waste materials include, but are not limited to, the following:

        U.S. Department of Labor, Occupational Safety and Health Administration
        (OSHA), including but not limited to:

        • Asbestos Standards for the Construction Industry Title 29, Part
          1926, Section 58 of the Code of Federal Regulations

        • Respiratory Protection
         Title 29, Part 1910, Section 134 of the Code of Federal Regulations

        • Construction Industry Standards Title 29, part 1926 of the Code of
        Federal Regulations

        • Access to Employee Exposure & Medical Records Title 29, Part 1910,
          Section 20 of the Code of Federal Regulations

        • Hazard Communication
          Title 29, Part 1926, Section 59 of the Code of Federal Regulations
        • Specifications for Accident Prevention Sign & Tags

         Title 29, Part 1910, Section 145 of the Code of Federal Regulations


        U.S Department of Transportation (DOT), including but not limited to:

        • Hazardous Substances
          Title 29, Parts 171 and 172 of the Code of Federal Regulations

        U.S. Environmental Protection Agency (EPA) including but not limited to:

        • Worker Protection Rule
         Title 40, Part 763, Subpart G of the Code of Federal Regulations

        • Asbestos hazard Emergency Response Act (AHERA) Title 40, Part 763,
          Subpart E of the Code of Federal Regulations

        • Regulation for asbestos
         Title 40, Part 61, subpart A of the Code of Federal Regulations

        • National Emission Standards for Hazardous Air Pollutants (NESHAP)
        Title 40, Part 61, Subpart M of the Code of the Code of Federal Regulations
                    ASBESTOS ABATEMENT GUIDELINES

      4.2.2   State and Local Regulations: All applicable state and local regulations which are in effect at the
              time of bidding the asbestos abatement project, and which have a direct bearing upon the project,
              will be included and incorporated by reference and made a part of the contact document. An
              example of this would be an asbestos abatement project at a school in the State of New Jersey. This
              project would be regulated by the Asbestos Abatement Act and Rules and Regulations for Private
              and Public schools in New Jersey. In addition to all applicable regulations pertaining to asbestos,
              GAC will also be required to comply with all applicable hazard communication and right-to-know
              laws, which have not been preempted by the federal hazard communication standard, 29 CFR
              1926.59.

4.3   Notification (Exhibit 1)

      All notifications must be made by registered mall with a return receipt requested.

      When doing either demolition or renovation, all requirements for notification and emissions control apply
      for RACM in amounts greater than 160 square feet, 260 linear feet, or 35 cubic feet.

      4.2.3    Environmental Protection Agency (EPA): GAC must notify, in writing, the Regional Office of the
               Environmental Protection Agency (EPA) of the planned asbestos abatement operation and of any
               significant changes to the plan:

                •    Notification must be received by the EPA at least 10 working days prior to beginning the
                     project;

                •    Notification must be received by the EPA at least 10 working days before the end of the
                     calendar year for nonscheduled operations or additive amounts;

                •    Notification must be received by the EPA as early as possible before, but no later that, the
                     following working day for certain demolition or renovation operations, such as emergencies,
                     unsafe buildings, etc.;

                •    An update notice must be sent to the EPA if the amount of asbestos noted in the original
                     notification changes by at least 20 percent, and

                •    A new notification is required to be sent to the EPA if the start date changes, If the start date
                     is later, the notification must be sent as soon as possible before the original start date. If the
                     start date is earlier, the notification must be received by the EPA at least 10 days prior to the
                     start date.
                                        ASBESTOS ABATEMENT GUIDELINES



        The required EPA Notification of Demolition and Renovation form (see exhibit 1) must be used to notify
        the EPA. Any other type of notification must include at least the following:

        a. The complete name, address and telephone number of the contractor;

        b.   The complete address and description of the location where the asbestos control operation will take
             place, including the size, age and use of the building and the amount of asbestos material present;

        c.   The complete name, address and telephone number of the actual owner of the building, which may
             differ form the name of the job site;

        d.   The procedures that will be employed to comply with the regulations; and

        e.   The complete name, address and telephone number of the waste disposal site where the asbestos waste
             will be deposited.

4.3.2   Other Regulatory Agencies: U.S. EPA’s 40 CFR 61 Subpart M requires that the notification dates pertain
        to the scheduled starting and completion of demolition and renovation. However, local jurisdictions can
        and often so, define these dates in many different ways, for example the start dates may be for any one of
        the following: Project mobilization, regulated area establishment, or actual abatement commencement.

        It is therefore imperative that the local requesting agency by contacted prior to issuance of the Notification
        in order to assure that the correct dates are furnished and specific local requirements complied with.

4.3.3   Communication on Multi-Employer Worksites (Exhibit 2): On multi-employer
        worksites, where the asbestos abatement operation requires the establishment of a regulated work area, and
        the requirements pertaining to this area.

        This is normally accomplished by GAC providing the owner with a letter in which this information is set
        forth. The owner then notifies the other employers and tenants whom he deems necessary and who are in
        the immediate vicinity of the regulated area.
                                ASBESTOS ABATEMENT GUIDELINES

4.4   Work Plan

      GAC will submit a site specific work plan of the procedures proposed for use in complying with the
      requirements of the asbestos abatement operation, the magnitude of which will be dependent upon the
      complexity of the removal project. Included in the plan will be the location and layout of the
      decontamination areas, the sequencing of the asbestos work, the interface of trades involved in the
      performance of work, methods to be used to assure the safety of GAC employees, building occupants and
      visitors to the site, the disposal plan including the location of the approved disposal site and a detailed
      description of the methods to be employed to control contamination.

      The work plan may be expanded to include the use of portable HEPA ventilation systems, closing out the
      building’s HVAC system, the method of removal to prohibit visible emissions in the work area, and the
      packaging of removed asbestos debris.

4.5   Environmental Issues

      An effort must be made to address all specific environmental issues that may emerge as a result of stating
      and completing the asbestos abatement project. In addition, future environmental issues, which may be a
      consequence of the completed project, must also be anticipated.

      Environmental issues management must be planned and conducted as an ongoing, organized activity
      during the project, mainly limited to immediate or near term regulatory concerns.

4.6   Contingency Plans

      GAC will prepare a contingency plan for any emergency, which may arise during the course of adequate
      medical attention in the event of an emergency.
      Many of these procedures are already included in the GAC Corporate Safety Program, which along with
      the other procedures and the telephone numbers and locations of emergency services, including but not
      limited to, fire ambulance, doctor, hospital, police, power company, telephone company, etc., will be
      located at the job site for employee information.

4.7   Incident Reporting


      In accordance with Section 3-1 of GAC ’s Corporate Safety Program, Incident Reporting, GAC will
      prepare and document reports of significant accidents at the job site and anywhere else that work is in
      progress in connection with the asbestos control operation. For this purpose, a significant accident is
      defined to include those injuries and illnesses deemed recordable on the OSHA 200 form, or where a
      property loss of substance is sustained.
                                ASBESTOS ABATEMENT GUIDELINES

4.8   Supplementary Conditions

            Where portions of the Guidelines are inappropriate for a specific project, or do not include needed
            provisions, Supplementary Conditions will be used to make the modifications and additions needed.

4.9   Smoking Cessation Policy

              In keeping with GAC ’s No Smoking policy and the smoking cessation, requirements imposed by
              OSHA’s Asbestos Standard, there will not be any smoking allowed within the work areas on any
              of GAC ’s asbestos abatement projects. The work area includes, but is not necessarily limited to,
              the office or office trailer, all regulated areas, the decontamination unit, employee lunch rooms and
              storage areas. Each of these areas will be posted with NO SMOKING signs. Smoking bans in these
              areas will be enforced. Smoking cessation programs will be the topic of frequent Tool Box Safety
              Talks and smoking cessation program information will be posted at all job sites. When considered
              necessary, the designation of a smoking area, will neither be located within the confines of the
              work area nor m an area where non-smokers can be affected by secondary smoke, may be
              permitted.

5.0   ADMINISTRATIVE AND SUPERVISORY PERSONNEL

      5.1     Education and Certification

              By Corporate directive, all GAC operations supervisors are required to have completed and
              passed, by written examination, an EPA Certified Training Center course in Supervision of
              Asbestos Abatement Projects (AHERA), and are further required to complete an annual update
              course in Advanced Supervision of Asbestos Abatement Projects. A copy of la current certification
              must be present at the job site for each supervisor assigned to the project on a full time basis.

              Where required by local or state requirements, supervisory personnel will either have or will
              obtain, prior to the start of work, the necessary certification for the asbestos abatement project. If
              required to do so by the contract documents, GAC will furnish the Owner, or the Owner’s
              representative with proof of this certification.

      5.2     Competent Person / On-sight Representative

              The project manager, Superintendent or General Foreman, assigned to the project will be GAC ’s
              Competent Person, as required by OSHA in 29 CFR 1926.58 (e) (ii), and the On-site
              Representative, as required by the EPA in NESHAP 40 CFR 61.145 (c) (8), and such, will have the
              necessary training, competency and authority to maintain this position.

              A Competent Person I On-Site Representative will be named for each work shift. This individual,
              or his designate, who must also have the necessary training, competency and authority, must be
              present at the job site, in the general vicinity of the work area, during the work shift for which he
              or she has been named Competent Person / On-Site Representative.
                   ASBESTOS ABATEMENT GUIDELINES

      The Project Manager, Superintendent or General Foreman will also be GAC ’s Representative for
      compliance with all applicable local, state and federal codes and regulations, particularly those relating to
      asbestos containing materials.



      In the event GAC should need to designate an employee of a sub-contractor as its Competent Person / On-
      Site Representative on a particular job site, that individual will have all of the necessary training, education,
      and written authority to comply with the requirements of the above named standards.

5.3   Project Manager/ Superintendent

      GAC will employ full-time personnel who will have the designation of either Project Manager or
      Superintendent, depending upon the organizational structure of the GAC location involved. These
      individuals will be experienced in administration and supervision of asbestos abatement projects, including
      work practices, protective measures for building and personnel, disposal procedures, respiratory protection,
      etc.

5.4    General Foreman (As Required)

       Except as otherwise indicated, the General Foreman will normally have the same education and training in
       asbestos control operations as the Project Manager or the Superintendent, with only slightly less on the job
       experience. Here again, if required to do so by law, the General Foreman will obtain all the necessary
       certification for the project. The General Foreman can also act as the GAC ’ s Competent Person on the
       job.

5.5   Foreman

      The Foreman is generally hired for a specific project and is usually obtained from either a local labor pool
      or an appropriate union hall. Efforts are made to hire individuals for this position who have had either
      previous experience as a Foreman on an asbestos abatement project or specific training in direct
      supervision.

5.6    Safety Coordinator

      GAC has designated an individual to be responsible for reinsuring compliance with all applicable
      standards of those local, state and federal regulatory agencies having jurisdiction over an asbestos
      abatement project as well as the specific health and safety requirements of the Corporate Safety Program.
      This individual, in addition to having successfully completed all of the required asbestos certification
      courses, has also received specialized training in OSHA Construction Safety Practices While not
      necessarily assigned to each asbestos abatement project on a full-time basis, the Safety Coordinator does
      conduct periodic safety audits and worker training at each site.
                                  ASBESTOS ABATEMENT GUIDELINES

6.0   WORKER PROTECTION

      Whenever GAC ’s personnel have the potential for exposure to air-borne asbestos fibers, the following will
      apply:

      6.1     Worker Training

                  In accordance with 29 CFR 1926.58, all employees who will be working in asbestos abatement
                  operations will be informed of the dangers inherent in handling asbestos, in the proper work
                  procedures, in the use of protective topics:

              •       Methods of recognizing asbestos and the health effects associated with it;
              •       Relationship between smoking and asbestos in producing lung cancer,

              •       Nature of the operations that could result in exposure to asbestos;
              •       Importance of and instruction in the use of necessary protective controls, and practices and
                      procedures to minimize exposure. This will include engineering controls, work practices,
                      respirators, housekeeping procedures, hygiene facilities, protective clothing, decontamination
                      procedures, emergency procedures and waste disposal procedures;
             •        Purpose, proper use, fit-testing, instruction, care, limitation, and
                      maintenance of respirators in compliance with 29 CFR 1910.134;

              •       Appropriate work practices for the work and the requirements of a medical surveillance
                      program;

              •       Explanation of differential pressure system, the air monitoring practices and personal
                      decontamination procedures; and
              •       The content of the OSHA Asbestos Standard, 29 CFR 1926.58, a copy of which is available

                      to the employee upon request.


      6.2     Respiratory Protection

             Except to the extent that more stringent requirements are written directly into the Contract, or
             required by local ordinance, Section 7-1 of the GAC Corporate Safety Program, Respiratory
             Protection, will have the same force and effect as if copied directly and the standards promulgated
             in the Applicable Codes listed in Paragraph 4.0 of these Guidelines, the more stringent
             requirements will be enforced.
                    ASBESTOS ABATEMENT GUIDELINES

       The respiratory protection intended for use in each operation of the asbestos abatement project will be
       identified on the Anticipated Respiratory Protection Requirements form (see exhibit 3), unless otherwise
       specified by the contract. The information contained on the Anticipated Respiratory Protection
       Requirements form is based upon airborne asbestos fiber counts encountered on previous projects of a
       similar type working on materials similar to those found on the projected asbestos abatement operation, or
       actual
       readings when they are current and available.

6.3 Protective Equipment

       In addition to respiratory protection, GAC requires the following protective equipment for the safety of its
       workers: (Refer to section 8-5, Personal Protective Equipment, in the Corporate Safety Program).

       6.3.1    Coveralls: GAC ‘will provide either disposable or reusable full
                body coveralls and head covers, and require that they be worn by all
                persons entering the work area.

                  GAC will provide a sufficient amount of protective clothing for the required number of changes
                  foe all workers in the work area. Disposable coveralls, once contaminated, will be disposed of
                  daily as ACM waste. In the event reusable protective clothing is used, these garments must be left
                  in the Equipment Room, having first removed all of their clothing in the Clean Room.

                  Upon completion of the project, the clothing and the washer and dryer will either be completely
                  decontaminated and removed for future use, or they will be properly disposed of as asbestos-
                  contaminated materials. Waste water from the washer will be either filtered through the shower
                  water filtering system or collected for use as amended water. The dryer will be vented into the
                  containment area or through a small HEPA filter attached to the vent pipe outlet.

        6.3.2     Foot Covers: GAC will provide either disposable or washable foot covers, which must be used
                  over, or in some cases in lieu of;, the employees personal footwear. If unable to adequately
                  decontaminate personal footwear, it must be properly disposed of as asbestos-containing material
                  (ACM) waste at the end of the project.

       6.3.3     Rubber Boots: When rubber boots are used in the work area, they will be required to remain in the
                 work area until the completion of the project, at which time they must be thoroughly cleaned and
                 decontaminated, both-inside and out and put into a plastic bag before removal from the area.
                 When working in areas requiring the use of safety shoes or boots, they must be disposed of as
                 ACM waste at the end of the project.

       6.3.4     Hard Hats: N1RAM will provide hard hats and require that they be worn at all times when
                 working on an asbestos abatement project. Contaminated hard hats must remain in the work area
                 until they will be appropriately cleaned or disposed
                ASBESTOS ABATEMENT GUIDELINES

      6.3.5   Safety Glasses and / or Goggles: Where required, GAC will provide eye
              protection in the form of either approved safety glasses or goggles for all employees on the job
              site. If taken into containment, the safety glasses and I or goggles must remain in the work area
              where they will be appropriately cleaned or disposed as ACM waste at the completion of the
              project.

              In those cases where additional eye potation is deemed necessary, this will be provided by N[RAM
              in the form of goggles. The same requirements for contaminated safety glasses also applies to
              goggles.

      6.3.6   Work Gloves: GAC will provide appropriate work gloves to all personnel in the work area. The
              gloves must remain in the work area until the completion of the project, at which time they will be
              appropriately cleaned ort properly disposed as ACM waste.

      6.3.7    Hearing Protection: GAC will administer and effective Hearing Conservation Program, as
               prescribed by OSHA in 29 CFR 1910.95, Occupational Noise Exposure, whenever employee
               noise exposures equal or exceed an 8-hour time weighted average (TWA) sound level of 85
               decibels (PB) measured on an appropriate noise dosimeter. Refer to section 7-3, Hearing
               Conservation Program, in the Corporate Safety Program. When worn in a contaminated area, this
               equipment will be disposed of as ACM waste at the end of the project.

6.4   Material and Equipment

      GAC will provide either new or used materials and equipment that is undamaged and in serviceable
      condition, and only that equipment that is recognized as being suitable for the intended use and in
      compliance with the appropriate standards.

      6.4.1   Scaffolding: GAC will provide all scaffolding, ladders and / or staging, etc. as necessary to
              accomplish the asbestos abatement project. The scaffolding may be of the suspension type or the
              standing type, such as metal tube and coupler, tubular welded frame, pole or outrigger type or
              cantilever type. The type, erection and use of all scaffolding will comply with all applicable OSHA
              Standards. At the conclusion of the abatement work, the scaffolding will be decontaminated before
              leaving the work area. Refer to section 8-8, Scaffold Safety, in the Corporate Safety Program.

               NOTE: Only those Supervisors or Foreman possessing a valid certification of scaffold training
               will be considered qualified to erect, modify, move or dismantle any type of scaffolding,
               regardless of the height of the scaffold.
                        ASBESTOS ABATEMENT GUIDELINES

            6.4.2    Water Services: Where required by the contract document, all connections to the Owner’s
                     water system will include valves that are temperature and pressure rated for operation of
                     use, connections and fittings will be removed without damage or alteration to existing
                     water piping and equipment. Only heavy duty abrasion-resistant hoses with a pressure
                     rating greater than the maximum pressure of the water distribution system will be used to
                     provide water to the work area of the decontamination facilities.

            6.4.3   Hot Water Heater: In the absence of hot water, GAC will provide a UL rated hot water
                    heater for the decontamination unit shower. Wiring of the hot water will be in compliance
                    with all applicable parts of the National Electric Code.

            6.4.4   Electrical Services: Except to the extent that other conditions are written directly into the
                    Contract, the Owner will provide electrical service and Section 8-7, Electrical Safety, in
                    the Safety Program, will have the same force and effect as if copied directly into the
                    contract.

            6.4.5   Ground Fault Circuit interrupter: Employee’s will not be permitted to work in any
                    asbestos containment area, in proximity to any part of an electric power circuit in which
                    they may come in contact during the course of this work, unless the employee is protected
                    against electric shock by use of a Ground Fault Circuit Interrupter.(GFCI). Refer to
                    section 8-7, Electrical Safety, In GAC ’s Safety Program.

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                   ASBESTOS ABATEMENT GUIDELINES

They must have received a medical examination in compliance with the medical examination requirements of
OSHA. Standard 29 CFR 1926.58 within the past twelve (12) months and have written certificate, or facsimile, from
the physician attesting to his opinion that the individual may enter an atmosphere in which the use of the respiratory
device, and when applicable, they must be fit-tested for the respiratory device; and they must receive adequate
training for entry to an asbestos containment area.

After they have met the above criteria, all personnel must enter the Clean Room and remove all street clothing,
including underwear and socks. Depending upon the individual’s preference, they can either continue to the next
step in the nude, put on disposable underwear or use a nylon bathing suit. The underwear and bathing suit are
general furnished by the individual.

A clean set of protective clothing must then be put on, leaving the head covering off. The individual must then don a
respirator approved for the project and conduct the necessary field check to determine the face-piece-to-face seal.
The head covering is then secured over the top of the respirator straps. The individual should then leave the Clean
Room and proceed through the Shower Area and enter the Equipment Room.

In those cases where the worker has been using any addition clothing or work tools, which have been left in the
contaminated end of the Equipment Room, these should be put on at this time before leaving the Equipment Room
and entering the work area.

All donning of respiratory protective equipment and protective work clothing should be accomplished using the
“buddy” system, involving two employees assisting each other.

Prior entering a work area, each worker should be examined by his “buddy” to ensure that all connections in the
respirator system are properly made and that the protective clothing, booties, head covers, etc. are properly donned.


6.6      Decontamination Procedures

         Before leaving the work area, all personnel are required to remove gross contamination and debris from
         their protective clothing and feet by either HEPA vacuum or wet wiping. The worker the proceeds to the
         Equipment Room and removes all clothing and equipment with the exception of respiratory equipment.

         All tools and extra work clothing, such as cold weather coats and pants, work boots or shoes, etc. which are
         contaminated, must remain in the containment area and should be stored in the dirty Equipment Room. All
         disposable protective clothing must be placed in an appropriately marked bag for disposal with other
         contaminated waste materials. All personnel are then required to use the following decontamination
         procedures when leaving the work area
             ASBESTOS ABATEMENT GUIDELINES

Still wearing the respirator, proceed to the showers. Showering is not only essential for decontamination, but is
mandatory under GAC Corporate policy. Care must be taken to follow reasonable procedures in removing the
respirator to avoid asbestos fibers while showering. The following procedures are required as a minimum:

6.6.1    Supplied-Air and PAPR Respirators: If using supplied-air or PAPR respirators thoroughly wet the body,
         including the face and hair. If using a PAPR, turn the blower unit down so that the filter opening is towards
         the chest.

          With the respirator still in place, thoroughly wash the body, the hair, the respirator face-piece and all
          outside parts of the respirator except the blower unit and the battery pack on a PAPR. Pay particular
          attention to the area around the seal of the face-piece and under the straps.

         Completely wet the hair, face and respirator. Take a deep breath and while holding it or exhaling its slowly,
         stand so that the water is directed at the face and remove the respirator and hold it away from the face
         before starting the breath normally.

         Carefully wash the face-piece of the respirator inside and out. If supplied-air, disconnect the air line. If
         PAPR, shut down in the following sequence. First, cap the inlet opening to the filter cartridge and then turn
         off the blower unit. (This sequence will help keep debris which has collected on the inlet side of the filter
         from dislodging and contaminating the outside of the unit).

          Thoroughly wash the blower unit and hoses and carefully wash the battery pack with a damp rag to avoid
          getting water into the battery pack.

          Shower completely with soap and water, paying special attention to areas containing body hair. Rinse
          thoroughly.

          Rinse the walls and floor of the shower stall prior to exiting. Proceed to the Clean Room to dry off and put
          on street clothing or a new set of protective clothing.

6.6.2     Air Purifying Respirators: For air purifying negative pressure respirators,
          thoroughly wet the head, neck and body as much as possible without wetting the respirator filter.

          Take a deep breath, and while holding it or exhaling it slowly, seal the filter cartridge inlet opening with
          either a piece of tape or a cap made for this purpose. Immediately wet the respirator and filter and while
          standing with face directed at the water, remove the respirator form the face and begin breathing normally.

          When disposing of the used filter cartridges, thoroughly wet the cartridge and dispose of it as
          contaminated waste. Then wash the face piece of the respirator, both inside and out.

          Shower completely with soap and water, paying special attention to all areas of
          body hair. Rinse thoroughly.
                                  ASBESTOS ABATEMENT GUIDELINES

              Rinse the walls and floor of the shower stall prior to exiting. Proceed to the Clean Room to dry off
              and put on street clothing or a new set of protective clothing.

              NOTE: all used filter cartridges which are to be replaced, must be put into an appropriate waste
              disposal bag which should be located in the air lock between the shower and the Clean Room.
              Under no circumstances should the ACM waste disposal bag be located inside the Clean Room.

      6.6.3   Towels and Bath Mats: All disposable towels, bath mats and shower cloths which are
              contaminated, must be treated as contaminated waste and properly disposed of.

6.7   Medical Examinations

      GAC will offer at no cost to the employee, a physical examination for all N1RAM personnel who are
      either working in an area which there is a potential exposure to asbestos, or who are required to use any
      type of respirator protection equipment. These physical examinations will, as a minimum, meet the
      requirements of the Medical Surveillance portion of the OSHA Asbestos Standard for the Construction
      Industry, 29 CFR 1926.58. As a part of the examination, the physician will also be asked to make an
      evaluation of the employee’s ability to work in environments capable of producing heat stress in the
      worker. Refer to section 7-1, Respirator Protection.

      In the event the employee will be working in an area in which there is an additional exposure hazard, for
      example, lead or P.C.B.’s, the medical examinations required by the appropriate OSHA Standard will also
      be provided.

      4.2.1    Report of Medical Examination: Al a minimum, the following information will be contained on
               each report of medical examination completed by the examining physician:

              a.      The name and social security number of the employee;

              b.      Whether or not the employee has any detected medical conditions that would
                      place the worker at an increased risk of material health impairment from exposure to
                      asbestos;

                   c. Any recommended limitations on the worker or on the use of personal protective equipment
                      such as respirators;

                   d. A. statement that the worker has been informed by the physician of the results of the medical
                      examination and of any medical conditions that may result form asbestos exposure; and

                e. A statement that the worker has been informed of the health risks involved in smoking, of
                   the synergistic relationship between smoking and asbestos exposure m producing lung
                   cancer and that cessation of smoking will reduce the risk of lung cancer. (Refer to Section 9-
                   2 Medical Surveillance Guidelines of the Corporate Safety Program).
                                ASBESTOS ABATEMENT GUIDELINES


      6.8    Emergency Procedures

              Emergency procedures must be developed prior to the initiation of abatement activities. The
              emergency procedures must be in written form and prominently posted in the site office and the
              employees’ eating area. Copies must also be posted m the Clean Change Room and the Dirty
              Equipment Room of the worker decontamination unit. Prior to entering the containment for the first
              time, everyone must read and sign these procedures to acknowledge receipt and understanding of
              the work site layout, location of emergency exits, emergency routes to follow and the emergency
              procedures.

              The emergency procedures must include considerations of fire, explosion, toxic atmosphere,
              electrical incidents, slips, trips and falls, confined spaces and heat-related injuries. Procedures
              must be written, emergency exits noted and marked, emergency evacuation routes mapped out,
              emergency and evacuation annunciation systems identified, emergency phone numbers listed and
              any other critical information, such as barriers that may affect response capabilities, must be
              included.

              Once these procedures have been posted, employees must be trained in these procedures. Refer to
              Section 4-1 of the Safety Program, entitled Emergency Action Plans.

              6.8.1    For-Non-Life Threatening Situations: Employees injured or otherwise incapacitated must
                       decontaminate following normal procedures, with assistance from fellow workers if
                       necessary, before exiting the work area to obtain medical treatment.

              6.8.2    For Life-Threatening injury or Illness: Measures to stabilize the injured worker, remove
                       him or her from the work area and secure proper medical treatment will take priority over
                       worker decontamination. Personal protective equipment should be available for response
                       team members needing to enter the containment.

7.0   DECONTAMINATION FACILITIES

       Unless otherwise directed by the contract document, and space not being a factor, N1RAM will provide
       separate personnel and equipment decontamination facilities. Under this provision, the Personnel
       Decontamination Unit will be the only means of worker ingress and egress to the work area. All
       contaminated material and equipment will exit the work area through the Equipment Decontamination
       Unit. In some cases, permanent-showering facilities may be utilized and in others GAC will either build a
       decontamination unit or furnish a prefabricated decontamination unit.
                    ASBESTOS ABATEMENT GUIDELINES

While the drawing at the end of 7.1 depicts the general arrangement of the type of decontamination facility used by
GAC , there are many specific arrangements, which may vary slightly but function the same as that shown in the
drawing. For example, the decontamination facility could be located parallel to the work area or it could be
perpendicular to it, it could be located inside the work area or it could be outside the work area. The only important
criteria for placement of the decontamination facility, is that it exits to the outside ambient surroundings only at the
clean end of the unit and exits into the isolated work area only at the equipment or dirty end of the unit. However,
space permitting, every effort should be made to locate the decon unit contiguous and adjacent to the work area.

7.1      Personnel Decontamination Unit (Decon)

         The Personnel Decontamination Unit will consist of a serial arrangement of five (5) connected rooms or
         spaces, designated the Clean Room, the Air Lock, the Shower Room, the Air Lock and the Equipment
         Room, separated by impermeable walls. Floor to ceiling height should not be less than 6 feet 6 inches.

         Access to each of these five connected rooms or spaces will be protected by constructing overlapping
         layers of 6-mu polyethylene (poly) plastic sheeting to form a double or triple barrier flap to each room or
         space. Construction materials may include two by fours, plywood, and 6 mu frosted, opaque or black,
         regular or fire retardant polyethylene sheets, to provide worker privacy and suitable framing.

         7.1.1    Clean Room: The Clean Room, or change room as it is sometimes referred to, is physically and
                  visually separated from the rest of the building for the purpose of allowing personnel to change
                  into protective clothing. It is constructed so as to have an airtight seal between it and the rest of
                  the building and designed so that access to the work area from the Clean Room is only through the
                  double or triple barrier flaps, made from several layers of overlapping 6-mu poly, to the Air Lock,
                  the Shower Room, the other Air Lock and the Equipment Room. Asbestos contaminated items are
                  not allowed to enter this room for any reason.

                    Entrance to the Clean Room from the outside uncontaminated area will be controlled by either a
                    set of the overlapping poly barrier flaps or a rigid door. In those cases where security is a
                    consideration, the rigid door will be used and outfitted with a hasp and padlock. Access to the
                    Clean Room from inside the decontamination unit will only be through a set of overlapping poly
                    barrier flaps separating the Clean Room from the Air Lock and the Shower Room. The Clean
                    Room will also act as a storeroom for employee’s street clothing, uncontaminated equipment,
                    such as respirators, towels, protective clothing, etc., and as an information center for the posting
                    of required documents and emergency information.

                    The floor of the Clean Room must be kept clean and dry at all times and all surfaces should be
                    damp wiped with a disinfectant solution after each shift change. An adequate supply of towels
                    and bath mats will be provided on a continuous basis.
            ASBESTOS ABATEMENT GUIDELINES

        The air monitoring contractor will be instructed to conduct a daily air sampling of the interior of the clean
        Room in order to insure that this area is constantly maintained as clean, with a fiber count at or below 0.01
        £/cc at al times.

7.1.2   Air Locks: The Air Lock is nothing more than a small room which occupies the space between the Clean
        Room and the Shower Room and Shower Room and the Equipment Room. There must be and Air Lock on
        both sides of the Shower Room. The purpose of these two extra rooms are to provide an additional measure
        of protection to prevent asbestos fibers form escaping the contaminated areas of the decon and entering the
        clean areas. The size of the Air Locks are determined solely by the amount of overall space available for
        the decon unit.

         Space permitting, the Air Lock between the Shower Room and the Clean Room can be used to store clean
         towels and floor mats, soap and shampoo and the waste disposal bag for asbestos-contaminated filters.

7.1.3    Shower Room: GAC will provide a completely water tight operational shower to be used for transit by
         cleanly dressed workers heading for the work area from the Clean Room and/or for showering by workers
         heading out of the work area after undressing in the Equipment Room. The Shower Room must be
         constructed in a “pass through” design, a configuration that will require the worker to pass from the
         contaminated Equipment Room, through the shower and into the Clean Room without stepping back onto
         a contaminated area. An adequate number of showers will be provided for the size of the project.

         For sanitary reasons, it is advisable to install a free draining floor on the top of the shower part, and the
         showerheads should be mounted so as to cause water running down the wails to drip into the pan. Each
         showerhead will contain both hot and cold water, which can be adjusted by the person taking the shower.

         The Shower Room must contain at least one shower and N]RAM must ensure that soap and clean towels
         are always present. The shower room must be cleaned and drained properly at the end of each work shift.

         Shower wastewater will either be drained or stored for use in amended water.
         Drains will be equipped with a approved filtering system, which provides as a minimum, 5 micron
         wastewater filters in line to appropriately filter the waste water for sewer disposal. Where required,
         approval will be obtained from the appropriate regulatory agency or commission for disposal of filtered
         wastewater into the local sewer system. Contaminated water can not be released to uncontaminated areas.
                  ASBESTOS ABATEMENT GUIDELINES


      7.1.4   Equipment Room: This is a change and transit room for personnel who have had access to the
              contaminated work area. All work equipment, footwear and additional contaminated work clothing
              must be left in this room. The Equipment Room will have two (2) exits, one leading to the
              contaminated area and the other to the overlapping poly barrier flaps leading into the Air Lock
              located between the Shower Room and the Equipment Room. If, for some reason, the airborne
              asbestos level in the work area is expected to be high, as in dry removal, an intermediate cleaning
              space will be added between the work area and the Equipment Room.

               On those removal projects that have a high amount of debris, it may be helpful to place an
               additional sheet of poly on the floor in the Equipment Room at the beginning of each day and
               removed at the end of the work shift. This will help to prevent the path from the work area to the
               shower from becoming overburdened with contaminated debris.

      7.1.5   Negative Pressure in the Decon: I order to prevent the escape of asbestos fibers from the decon, it
              will be necessary to maintain a constant inward flow of air flow of air form the outside of the Clean
              Room through the Air Locks and Shower Room and into the Equipment Room. This sole source of
              airflow must originate from the uncontaminated area outside the asbestos removal, demolition or
              renovation enclosure. Since a negative pressure system normally exists inside the work area, this
              lower pressure may already create a sufficient inward flow of air to provide the degree of protection
              necessary to prevent the escape of fibers.



               However, if a simple smoke test, performed at the entrance to each room in the decon, does not
               indicate a satisfactory inward air flow, it will be necessary to install a separate negative air
               handling unit in the Equipment Room, an adequately sized unit capable of creating a differential
               pressure which will develop the required inward air flow. If a rigid door is used to control access
               to the Clean Room from the outside area, it may be necessary to control the flow of inward air by
               installing a louvered opening in the rigid door. If the louvered opening in the rigid door. If the
               louvered door is used, the opening must be protected with a High Efficiency Particulate Air
               (HEPA) filter, that is certified to be at least 99.97 percent efficient for 0.3 micron particles, to
               prevent the escape of asbestos fibers in the event the negative pressure system should fail.

7.2    Material Decontamination Unit

       The material decontamination unit, or bag Out Area as it is commonly referred to, is generally required
       only on large asbestos abatement projects or as an emergency exit. If required to do so as a part of the
       contract document and where space permits, the material removal area will be constructed by GAC
       according to the following:
ASBESTOS ABATEMENT GUIDELINES                                                                                         __


      7.2.1   Material Decontamination Area: Space permitting, the bag Out Area will be constructed at some
              location away from the personnel decontamination unit. Whenever possible, this will be located
              where there is direct access from the work area to the outside of the building. This consists of a
              clean area which opens to the outside, a wash room which opens to the contaminated work area
              and an air lock which separates the clean area and the wash room. The openings to each of these
              areas are controlled by barrier flaps constructed of several sheets of overlapping 6-mil poly. Here
              again, as in the personnel Decontamination Unit, an inward flow of air is required to prevent the
              escape of asbestos fibers to the outside air.

              However, due to the smaller size of the Bag Out Area, the negative pressure system m the Work
              Area is usually more than su~cient to produce this inward flow of air.

              Some type of water spraying unit should be used in place of a shower
              head and controls in the wash room, and it should have a pan large
              enough to catch the amount of water required to wash off bags containing
              contaminated waste materials. This wastewater should be appropriately
              filtered and discharged or stored for use as amended water in the work
              area.

              Personnel working in the material removal area will not use this as a means
              of egress form the work area except in the case of an emergency.

7.3   Material Decontamination Procedures

      7.3.1   Exiting the Work Area: While still in the work area, the appropriately bagged asbestos-
              contaminated waste materials will be properly sealed with a “goose neck” seal and then a HEPA
              vacuum will be used to remove the gross contamination form the bags. The bags will then be
              moved into the wash room of the Bag Out area.

              There, the seals will be checked and all bags or waste packages will be thoroughly washed and
              decontaminated before being moved forward into the air lock area. The workers who have just
              completed washing the waste material will not proceed into the air lock or the clean area, but will
              return to the work area, leaving the decontaminated bags of waste stored in the air lock area.

      7.3.2   Entering the Clean Holding Area: Workers, who are dressed in clean,
              uncontaminated protective clothing and wearing an appropriate respiratory protection, will enter
              the clean area of the Bag Out Area form the outside and remove the bags of contaminated waste
              from the air lock by reaching into the air lock and pulling the bags through the barrier flaps into
              the clean room. These “clean” workers will not proceed any further inside the Bag Out Area than
              the clean area and will not go through the air lock into the dirty area. Once the bags are inside the
              clean area, they will be placed into a second bag, the appropriate generator label will be placed
              between the two bags and the second bag will be “goose neck” sealed. The completely
              decontaminated bag will then be removed form the clean area to the outside storage area.
                                 ASBESTOS ABATEMENT GUIDELINES

7.4   Remote Decontamination Facilities

      In unusual situations, alternate methods of providing decontamination facilities may be utilized on
      accordance with all applicable codes and regulations.

      Such a case in point may be the requirement to locate the decontamination facility a considerable distance
      away from the work area, even to the extent of locating it several floors above or below the floor housing
      the work area. In cases to this type, a small room would be constructed at one point in the work area. In
      cases of this type, a small room would be constructed at one point in the work area that would open to the
      outside of the work area, with both the inner and outer openings controlled by overlapping 6-mil poly
      barrier flaps. The worker would enter this small room directly form the work area, a HEPA vacuum would
      be used to remove any gross contamination on the worker, the outside of the respirator would be washed
      off, and the worker would put on a clean set of protective coveralls over the dirty ones. The worker would
      then proceed by the shortest route directly to the decontamination facility and once there, would follow the
      routine sequence for decontamination.

7.5   Cleaning Decontamination Units

      The debris and residue from inside the decontamination units will be cleaned on a daily basis or as
      otherwise indicated on the contract documents. The cleaning will consist of damp wiping or hosing down
      all surfaces after each shift change.

      7.5.1    Discharge of Waste Water: In the unlikely event that the Clean Room of the personnel
               decontamination unit should become contaminated with asbestos-containing debris, it will be
               necessary to close down the entire decontamination unit and erect a temporary new one until such
               time as the dirty unit can be completely decontaminated. The reason for this being that if the
               Clean Room becomes contaminated, there is no place for the worker cleaning it to be
               decontaminated.

7.6    Discharge of Waste Water

      Shower waste water should be filtered through 5 micron waste water filters and recycled for use as a
      wetting agent and br added to the 6-mil bags of asbestos-contaminated waste before sealing the bags for
      disposal in an approved landfill. If at all possible, this filtered waste should be reused and not just disposed
      of in sewer system.

       However, if it is necessary to dispose of clean, filtered waste into a city sewer system, a special permit
       may be required before this can be done. In some areas, local restrictions will not allow the disposal of
       this wastewatcr into a sewer system even if filtered. A thorough effort must be made to determine what
       the requirements are for disposing of wastewater in each location prior to the start of the project
                               ASBESTOS ABATEMENT GUIDELINES

8.0   TEMPORARY ENCLOSURE (WORK AREA)

      8.1 General

              The work area is the location where the asbestos abatement work occurs. It may be a portion of a
              room, a single room, or several rooms, or it may, in some cases, be located outdoors, such as an
              outdoor boiler. The work area is considered contaminated during the abatement work and must be
              isolated form the balance of the building.

              The work area must then be decontaminated at the completion of the asbestos abatement work.
              The enclosure, by which this contaminated area is isolated, is known as the temporary enclosure or
              the critical barrier. On those abatement projects where the work area is outside of a building, it
              may not always be necessary to build an enclosure in order to isolate it.

              The work area will be completely isolated form the other parts of the building so as to prevent
              asbestos-containing dust or debris from passing beyond the isolated area. Should the area beyond
              the work area become contaminated with asbestos-containing dust or debris as a consequence of
              an accident or a spill, those areas must be cleaned in accordance with appropriate and approved
              procedures.

              Unless otherwise specified by the contract document, all uncontaminated movable furniture,
              equipment, etc. will be cleaned with a H.EPA filtered vacuum cleaner and removed from the work
              area before commencing the abatement work. Those items that can not be removed will be cleaned
              with a HEPA filtered vacuum cleaner or wet wiped and then covered with one or two layers of
              poly sheeting, properly taped. This covered furniture or equipment will then be considered as
              “outside” the work area unless the poly covering or seal is broached.

              Unless otherwise specified in the contract document, all heating air conditioning, ventilation or
              return air system openings within the work area must be completely shut down and sealed off with
              poly and tape. Caution must be taken to check with the Owner to ensure that this sealing off of the
              HVAC system will not cause any undue problems.

             8.1.1     Critical Barrier: GAC will construct a critical barrier, which will ensure the work place
                       is isolated and contained, by erecting impermeable barriers at all exits or openings,,
                       including doorways, duct chases, manholes, mechanical shafts, elevator shafts, floor
                       openings, drains and the like, so that all possible exit or entrance routes are effectively
                       barricaded and sealed.

             8.1.2    Work Area Preparation: When not desirable to provide extensive
                      work area preparation installation as a general measure, plastic
                      sheeting will be used, but only where there is specific need to protect
                      particular items, areas or finishes from damage or temporary
                      contamination.
                                ASBESTOS ABATEMENT GUIDELINES

8.2   Access Control

      Access to the work area will be permitted only through the personnel decontamination unit. All other
      means of access will be closed off and sealed and warning signs will be displayed on the clean side of the
      closed access. No one will be allowed to enter the work area who does not have a direct need to do so.
      Persons entering the work area must follow all entry procedures, including the signing in and lout on the
      Containment Record, the removal of street clothing, donning protective clothing, using the appropriate
      respiratory protective device, and complying with all of the requirements of GAC ’s respiratory protection
      program and medical surveillance program.

      Depending on the nature of the abatement project, the respiratory protection being used, and the air
      monitoring results, persons desiring entry to the work area may be required to show verification of a
      physician’s clearance allowing the individual to use a respirator and enter and asbestos-containing
      atmosphere.

8.3   Warning Signs

      GAC will post a sufficient number of appropriately worded warning signs to adequately notify all persons
      in the vicinity of the work area of the dangers involved. The signs will normally be posted directly onto
      the clean side of the work area isolation barrier and at each entrance to the work area and the
      decontamination units. In some, states, it may be necessary to post these warning signs at least three (3)
      days prior to beginning asbestos abatement and to keep them until final clean results are received.

      The GAC warning signs, which are 20 inches high by 14 inches wide, comply with the requirements of
      the Occupational Safety Administration’s standard on warning signs, 29 CFR 1910.45. Each sign has the
      following legend and is red, white and black in color:

                                                 DANGER

                                                ASBESTOS

                               CANCER AND LUNG DISEASE HAZARD

                           RESPIRATORS AND PROTECTIVE CLOTHING
                                 ARE REQUIRED IN THIS AREA
                        ASBESTOS ABATEMENT GUIDELINES                                                                -~




9.0   NEGATIVE PRESSURE SYSTEM

      The Negative Pressure System is a fully operational engineering control system, which exhausts only the
      minimum amount of air from the work area necessary to create a continuous negative pressure of —0.02 to
      —0.04 inches of water within the enclosure with respect to the area outside the enclosure.

      This is achieved by using an Air Filtering Device (AFD), which is a self-continued filtering machine
      capable of producing airflow and using HEPA filter to collect and retain the airborne asbestos fibers.

      The methodology used in the Negative Pressure System is to seal all potential air paths into the work area
      as tightly as possible and provide a filtered exhaust system which removes only enough air from the sealed,
      isolated work area to establish a lower pressure to offset any air leakage which occurs, and to provide
      additional engineering controls within the work area to lower airborne asbestos fibers.

      NOTE:             Once the asbestos abatement operation has begun, and the negative pressure system has
                        been activated, the negative pressure must be maintained continuously until the air
                        monitoring reports indicate the area is no longer contaminated.

      9.1      Establishing Negative Pressure

               After construction of the enclosure is completed, a ventilation system(s) should be installed to
               create a negative pressure within the enclosure. Such ventilation systems must be equipped with
               HEPA filters to prevent the release of asbestos fibers to the environment outside the enclosure and
               should be operated 24 hours per day during the entire project until the final cleanup is completed
               and the results of the air samples are received from the laboratory. EPA requires that a sufficient
               amount of air be exhausted to create a minimum pressure of —0.02 inches of water within the
               enclosure with respect to the area outside the enclosure.

               However, that recommendation was offered at a time when most abatement was taking place in
               schools during summer recess. Removal of ACM in occupied high rise office buildings,
               apartments, hotel and hospitals is a more complicated undertaking, requiring a firmer control over
               the airborne fibers. This additional control of the fibers via increased negative pressure in the
               work space is necessary to overcome the existing resident air movement in the facility that could
               wrest the fibers from the abatement operations and into the occupied spaces. The exact pressure
               differential required will vary from project to project, depending upon how difficult it may be for
               the contractor to seal the area and how much existing air movement he may competing with from
               other building sources. In other words, exactly how many air changes per hour should be
               specified for the project depends on the overall project design.

               From a practical standpoint, this pressure differential should not be above the —0.06 inches of
               water column range, since anything higher begins to “float” the plastic off of the walls and floor.
                  ASBESTOS ABATEMENT GUIDELINES

      This ventilation system(s) should exhaust the HEPA filtered clean air outside the building in which the
      asbestos removal, demolition or renovation is taking place. If access to the outside is not available, the
      ventilation system can exhaust the HEPA-filtered asbestos-free air to an area within the building that is as
      far away as possible from the enclosure. Care must be taken to ensure that the clean air is released either to
      an asbestos-free area or in such a way as not to disturb any asbestos-containing materials.

9.2   Estimating Number of Air Filtering Devices

      A portable ventilation system, identified by GAC as an Air Filtering Device (AFD). is necessary to create
      a Negative Pressure System within the asbestos enclosure. The AFDs are designed to capture and clean the
      air inside the enclosure before exhausting it to the outside of the enclosure. The AFDs must be equipped
      with a series of filters which include: the first stage of pre-fllter, which is low-efficiency type filter for
      particles 100 urn and larger; the second stage or intermediate filter, which is a High Efficiency.
      Particulate Filter having an efficiency of not less than 99.97 percent. AFDs are available from several
      manufactures and range from 600 GEM to over 2000 GEM and are capable of filtering particles of 0.3
      micron in size with an efficiency of 99.99 percent. The number of capacity of AFDs are required to
      ventilate an enclosure depends on the size of the area t be ventilated.

      Lacking specific air monitoring data, which would indicate the number of Air Filtering Devices (AFD)
      required in the work area to provide a fully operational Negative Pressure System, GAC will estimate the
      number of AFDs needed in the following manner:

      To determine the number of AFDs required, GAC will ascertain the volume, in cubic feet, of the work
      area by multiplying the floor area by the ceiling height The total air circulation requirement for the work
      area, in cubic feet per minute (GEM), will then be determined by dividing the above volume by the number
      fifteen (15), which is 4 changes per hour.

      Volume of Work Area (cu. Ft.) = Air Circulation

                         15                 Requirement (GEM)

      The number of Air Filtering Device needed to achieve this rate will then be determined by dividing the air
      circulation requirement (CFM) by the working capacity of the AFS(s) used.
       Air Circulation Requirement (GEM)                                      Number of

       Capacity of AFD with loaded filter (GEM)                               AFDs needed


      Normally, one (1) additional AFD is added as a backup in case of equipment failure or if a machine needs
       to be shut down for filter changing.
                                ASBESTOS ABATEMENT GUIDELINES

      The Negative pressure System relies on monitoring results to dictate machine usage, and not on a passive,
      inactive system deployed on the basis of standard calculations which do not anticipate the peculiarities of
      each work area. Further, the Negative pressure System had an active, positive control over the airflow in
      the work area with an arrangement that can be freely changed to react to the air movement and fiber
      dynamics of each individual project. The monitoring results and patterns, therefore, can be used to
      maximize system effectiveness.

9.3   Positioning the Air Filtering Devices

      Locate the AFDs so that makeup air enters the work area primarily through the air entry routes of the
      decontamination facilities, both personnel and material, and traverses the work area as much a possible.
      This may be accomplished by positioning the HEPA filtered AFDs at a maximum distance from the worker
      access opening or other makeup air sources.

      Additional AFD machines could be located free standing inside the work area to circulate air within the
      area in order to filter and trap contamination out to the air. Depending on work methods, other engineering
      controls, the form or type of asbestos and its material characteristics, and previous treatments, the number
      of machines may be varied as little or as much as needed to lower the airborne fiber levels in the work area.

      NOTE:              Care should be taken to avoid having the exhaust opening of the AFD directed at the
                         plastic walls of the containment area or at any of the sealed openings.

      9.3.1    Exhausting the AFD: AFDs should, whenever possible, be exhausted outside of the building,
               however, in some areas, a special permit may be required before you are allowed to exhaust and
               AFD directly into the atmosphere outside a building or containment. Every effort must be made to
               determine the local requirements for exhausting AFD air before beginning the project and then
               complying with these requirements during the completion of the project.

               in order to insure protection of the environment, AFDs should have either an electrical or
               mechanical lockout to prevent the fan from operating without the HEPA filter in place. In
               addition, periodic air sampling of the AFD exhaust should be obtained to insure the integrity the
               HEPA filtering system.



      9.3.2    “Clean Air Island” Capability: To achieve a “Clean Air Island”, which is a clean, filtered
               envelope of air surrounding a worker or activity, the exhaust end of an AFD can or may de
               directed specifically at the individuals immediate local work area. Using the “push-pull” principal,
               the filtered exhaust air will push any released asbestos fibers away from the worker, thereby
               allowing the worker’s personal protective equipment and clothing to endure less fibers challenge
               and the worker’s personal safety will be enhanced.
                                  ASBESTOS ABATEMENT GUIDELINES

       9.4    Monitoring the Negative Pressure

              A manometer or pressure gauge for measuring the negative pressure within the enclosure must be
              installed at the enclosure on each GAC project, and must be monitored frequently throughout all
              work shifts during which asbestos removal, demolition or renovation take place. Although several
              types of manometers and pressure gauges are available for this purpose; for this use it is
              recommended that a strip-tape or wheel cart- recording manometer be utilized on each project. A
              manometer of this type will continuously monitor and, record the pressure differential between the
              work area enclosure and the building outside of the work area on a strip tape or wheel cart. When for
              some reason, a manometer is not being used; a nonirritant smoke should be used at least twice per
              work shift to verify the direction of air movement within the decontamination facility and the work
              area to verify negative pressure.

       9.5    Other Considerations

               Under certain conditions, other hazards must be given consideration. For example, high work area
               temperatures, gaseous or organic contaminants may dictate a need to increase exhaust air. These
               hazards must be considered and balanced one against the other. If the other contaminants can not be
               eliminated or filtered, or if cooling devices are not available to reduce temperatures, then additional
               air exhausting may be necessary. In these cases, exhaust may be increased or machine positioning
               may be changed until the other contamination levels, temperature, etc. are reduced to acceptable
               levels. This must be done with extreme care however, since each unit of additional exhaust to the
               outside increases the risk of contamination release in the event of an accident or component failure.
               If air inlets are provided to introduce make-up air, they must be monitored, provided with fixed
               doors, which are closed when not in use, or equipped with HEPA filters to prevent contamination
               escape.

       9.6    Dismantling the System

               When the final inspection and results of the final air tests have indicated the work area has been
               completely decontaminated, the Air Filtering Devices may be turned off and removed from the
               work area.

               Before removal form the work area, the prefilter of the AFDs should be removed and properly
               disposed of as contaminated waste, and the intake opening of the machine should be sealed with 6
               mil poly to prevent environmental contamination from the balance of the machine’s filters. Refer to
               Section 8-12 Decontamination.

10.0   NESHAPS ASBESTOS CATEGORIES

       10.1     Friable Asbestos-Containing Material (ACM)

                Friable asbestos-containing material (ACM) is defined by NESHAPS as any material containing
                more then 1 percent asbestos as determined using the Polarized Light Microscopy (PLM) method,
                that, then dry, can be crumbled, pulverized or reduced to powder by hand pressure. Local or state
                regulations may be more stringent.
                                 ASBESTOS ABATEMENT GUIDELINES

       10.2    Nonfriable Asbestos-Containing Material

              Nonfriable ACM is any material containing more than 1 percent asbestos as determined using
              Polarized Light Microscopy (PLM) method, that, when diy, cannot be crumbled, pulverized or
              reduced to powder by hand pressure. EPA also defines 2 categories of nonfriable ACM.

       10.3   Category I — Nonfriable ACM

               Category I nonfriable ACM is any asbestos-containing packing, gasket, resilient floor covering or
               asphalt roofing products which contains more than 1 percent asbestos as determined using the
               Polarized Light Microscopy (PLM) method, and which is in good condition and not considered to
               be friable.

       10.4    Category II— Nonfriable ACM

                Category II nonfriable ACM is any material, excluding Category I nonfriable ACM, containing
                more than I percent asbestos as determined using the Polarized Light Microscopy (PLM) method,
                that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Category
                II ACM (cement siding, transite board shingles, etc.) subjected to intense weather conditions such
                as thunderstorms, high winds or prolonged exposed to high heat and humidity may become
                “weathered” to a point where they become friable.

       10.5    Regulated Asbestos-Containing Material (RACM)

              Regulated asbestos-containing material (RACM) is friable asbestos material, category I nonfriable
              ACM that has become friable, category I nonfriable ACM that will be or has been subjected to
              sanding, grinding, cutting or abrading, or category II nonfriable ACM that has a high probability of
              becoming or has become crumbled, pulverized or reduced to powder by the forces expected to act
              on the material in the course of demolition or renovation operations.

11.0   REMOVAL OF ASBESTOS-CONTAINING MATERIAL (ACM)

       After preparation of the decontamination units, enclosure of the work area, and start up the negative
       pressure system, the gross removal of asbestos-containing material may begin.

       11.1    Access to Asbestos-Containing Materials

               Prior to actual removal of asbestos-containing material, it may be necessary to dismantle ceilings,
               electrical, or mechanical systems in order to gain access to the asbestos-containing material. The
               dismantled components will either be cleaned, protectively wrapped and stored for reuse,
               preferably outside the work area or the components will be properly decontaminated and disposed
               of as general construction trash. However, if the decision is made not to decontaminate the
               components, they must be properly packaged, labeled, and disposed of as asbestos-containing
               waste.
                                 ASBESTOS ABATEMENT GUIDELINES

11.2   Amended Water

       Prior to beginning any part of actual ACM removal, GAC must use amended water to thoroughly soak or
       wet down the asbestos-containing material sufficiently to retard the release of asbestos fibers during
       disturbance of the material. The amended water penetrates more effectively than plain water and permits
       more thorough soaking of the ACM. The amended water is generally prepared by mixing at least one ounce
       of surfactant (wetting agent) to 5 gallons of water.

        The amended water is applied to at he ACM with an airless sprayer, which will allow the amended water
        to be applied in a fine spray that minimizes the release of asbestos fibers by reducing the impact of the
        spray on the material to be removed.

11.3    Other Removal Agents

        In some cases, GAC will find it necessary to use other removal agents. For example, a penetrating type
        encapsulant designed specifically foe removal of asbestos-containing materials. When using such a
        removal encapsulant, it may be necessary to remove the ACM from the substrate before the encapsulant
        hardens or becomes dry.

11.4   Wet Removal Procedures

        In order to thoroughly soak or wet down the asbestos-containing material, GAC must spray the material
        with amended water or other removal agents, using spray equipment capable of providing low pressure
        application t reduce the release of fibers.

       The material must be saturated sufficiently to wet it to the substrate without causing excessive dripping.
       The asbestos-containing material will be sprayed repeatedly during the work process to maintain an
       adequately wet condition to minimize asbestos fiber release. The saturated asbestos-containing material
       should be removed in small sections, and if possible, placed directly into the disposal bags as it is removed.
       The ACM can not be allowed to fall or be dropped to the floor during the removal process, nor can the
       asbestos-containing material be allowed to dry out during this procedure.

        Asbestos-containing debris must not be allowed to accumulate on the floor of the work area. Any material
        that has not been bagged during the day must be bagged prior to the end of each work shift. Where
        possible, nonmetallic shovels should be used. Appropriately bagged waste material will be held in the
        staging area until such time as it is forwarded to the disposal site.

        In areas where the asbestos-containing material is more than 1-inch thick, total
       penetration or saturation may not occur, thus resulting in partially wet removal. When this happens,
       periodic misting with amended water of the surfaces and the surrounding atmosphere is required to ensure
       that the asbestos fibers do not dry out and become airborne.
                   ASBESTOS ABATEMENT GUIDELINES

        11.4.1   Freezing Temperature: When the temperature at the point of wetting is below 32 degrees
                 Fahrenheit, the requirements of adequately wetting the ACM can be discontinued. During periods
                 when wetting operations are suspended due to freezing temperatures, GAC must record the
                 temperature in the area containing the ACM at the beginning, middle and end of each workday
                 and maintain these daily temperature records for a period of two years, making them available to
                 the EPA when requested.

1.1.5   Negative-Air bag

        Using Negative-Air Bags to remove pipe insulation in the following manner, under contmuos negative
        pressure and with all of the other provisions of the Standard in operation, meets both the letter and the
        intent of the Standard with regard to removal practices and procedures.

        •    Each Negative-Air Bag will be used only once, and the application will be performed by a minimum
             of two (2) workers operating as a team to engage the bag, apply the negative pressure, wet the
             asbestos-containing materials, remove the asbestos, seal and remove the bag. This requirement to have
             at least two persons assigned to each Negative-Air Bag must be compiled with whenever feasible. In
             the unlikelihood the physical location of the removal site absolutely limits the number of workers
             doing ...~.-the removal, the second worker must remain in the immediate vicinity to be available for
             assistance when needed.

        •    A normal glove bag must be modified in such a way as to be able to maintain continuous negative
             pressure inside the bag. By doing this, the bag then becomes a Negative-Air Bag. The integrity of the
             negative pressure system must be demonstrated by smoke testing.

        •    The area to be worked on must be established as a regulated area with barrier tape and appropriate
             warning signs. All employers within the immediate vicinity must have been notified of the abatement
             project. Appropriate respirators and protective clothing must be provided and worn.

        •.   The area of insulation to be removed must be wet-wiped and sprayed with amended water or removal
             ençapsulant prior to attaching the Negative-Air Bag.

        •    The Negative-Air Bag must be attached to the pie using approved methods. If the size of the pipe
             warrants it, a small rigid collar may be inserted into the bag to insure that the bag does not collapse
             when negative pressure is created. All of the necessary tools and equipment must be inserted into the
             bag prior to its being sealed and placed under negative pressure.

             •   The method by which the bag is brought under continuous negative pressure is left to the decision
                 of the worker. Depending upon the method used, be it a HEPA vacuum, a back pack vacuum, a
                 PAPR air pump motor, a small AFD unit, or any negative pressure has been established, it must
                 remain continuous until the removal job has been completed.
                      ASBESTOS ABATEMENT GUIDELINES

           •      GAC must begin the removal process by using all of the normal engineering controls, including
                  the use of amended water. During the removal process, personnel air sampling must be conducted
                  in accordance with air monitoring requirements of the Standard.

           •      When the removal of the insulation has been completed, the Negative-Air Bag must be removed by
                  the approved method and then handled the same as any ACM waste. The removal process must be
                  thorough and must include encapsulant being sprayed onto the ends of any remaining insulation
                  and onto the open ends of the pipe.

           •     When the removal of the asbestos-containing material has been completed, all of the workers
                 involved must undergo a complete decontamination process in the decontamination unit, which has
                 been set-up nearby.

11.6   HEPA Vacuum Trucks

       If the decision is made to utilize a HEPA Vacuum Truck for the removal and/or disposal of friable
       asbestos-containing material being stripped and removed from a facility, GAC must make every effort to
       determine if prior approval, or notification, is required by a local or state regulating agency.

       Regardless of the removal method, wet dry or a combination of wet and dry, to be used in conjunction with
       the use of the HEPA Vacuum Truck, the following safety measures must be followed:

       •       Ensure that applicable, local exhaust ventilation and collection systems exhibit no visible emissions of
               asbestos particles or fibers to and/or into the ambient outside air during the operation and use of such
               systems at the asbestos abatement site.

       •       Make certain that an automatic system has been installed to shut down each baghouse at any time
               pressure drop reaches 25 percent of a pre-determined safe, adequate, and operational value for each
               baghouse.

       •       Ensure that there no visible emissions of asbestos articles or fibers to the outside air during the
               collection, processing, packaging, transporting or deposition of any asbestos containing waste material
               generated through the use of a HEPA Vacuum Truck.

       •       Ensure that the asbestos removal and collection vacuum system in each HEPA Vacuum Truck
               performs at a minimum collection efficiency of 99.99 percent.

       •       Ensure that no visible emissions of asbestos particulate matter occurs during the servicing of the
               vacuum system or during disassembly operations, that no asbestos contaminated water leaks from the
               door or other areas of the collection reservoir after vacuum shut-off.
                       ASBESTOS ABATEMENT GUIDELINES                                                                      —~


        •     Ensure that part of the HEPA Vacuum Truck exterior body and frame is contaminated with asbestos
              during disposal operations; however, if this should occur, then have a plan developed to take adequate
              precautionaiy measure while cleaning and decontaminating such surfaces.

        •      Ensure that any asbestos-contaminated water be adequately filtered prior to disposal m an appropriate
               manner and that any exhaust which could contain asbestos particles be monitored and tested during
               operation of the HEPA Vacuum Truck.

        •      Ensure that all personnel working directly with or on a HEPA Vacuum Truck be equipped with
               protective coveralls and respiratory protection and that a personnel decontamination unit is available
               nearby.

11.7    Packaging Asbestos Waste for Disposal

        Unless otherwise required by the contract document, GAC will place the asbestos waste into appropriately
        labeled 6-inil thick impermeable polyethylene plastic disposal bags. The bags should not be filled more
        than 40 percent by volume to avoid tearing. The ACM waste must be wetted with sufficient water to insure
        that is adequately wet.

            Prior to gooseneck sealing, the bag should be collapsed to remove any irapped air that may later contribute
            to bursting. After the exterior of the sealed bag is wet cleaned to remove any gross material, it is then
            double bagged and sealed by goosenecking and taping. The bagged and labeled ACM waste will than be
            stored in a secured container to await transport to the disposal site. Asbestos waste can not be mixed with
            any other type of construction waste form the site. Personnel handling ACM waste outside of the
            containment must wear, as a minimum, protective clothing and a HEPA equipped half-mask, air-purifying
            respirator. Before starting removal, GAC will have a sufficient number of waste disposal bags on site.

        11.7.1      Adequately Wet: NESHAPS describes the wording adequately wet as meaning to sufficiently mix
                    or penetrate the ACM with a liquid to prevent the release of particulates. An adequate amount of
                    the liquid control device (amended water) must be mixed with the ACM to form a slurry. GAC
                    will make certain that enough water is in each bag of ACM to readily enable an observer to view
                    the water without having to open the bag.

       11.7.2      Leak-Tight Seal: NESHAPS states that each bag containing asbestos materials must have a “leak-
                               tight” seal. This means that solids of liquids cannot escape or spill out.
                                    ASBESTOS ABATEMENT GUIDELINES

         It also means dust-tight Since NESHAPS also requires that the bagged ACM be
         sufficiently wet, a proper seal must also ensure that the water in the bag does not have sufficient air to
         evaporate thereby allowing the fibers to dry our and become airborne. In order to accomplish this “leak-
         tight” seal, the two bags must be individually “goose neck” sealed. This is done by twisting the top of the
         bag to form a long twist and then bending over the top of the twisted portion and taping it to the bottom of
         the twisted portion, thereby forming the “goose neck”. In doing this, a small amount of air is trapped in the
         gooseneck, which provides a leak-tight seal. Each of the two bags must be separately sealed in this manner.

11.7.3   OSHA Warning Labels: In compliance with the OSHA Asbestos Standard,
         29 CFR 1926.58, the OSHA Hazard Communication Standard, 29 CFR 1926.59, and the EPA NESHAP
         Standard, all of which require each employer to ensure that all containers of hazardous chemicals in the
         workplace are labeled, tagged or marked with the identity of the hazardous chemical contained therein, and
         an appropriate warning of the hazards or the chemical, all asbestos-containing waste disposal bags utilized
         by GAC will be appropriately marked as follows:

                                              DANGER
                                      CONTAINS ASBESTOS FIBERS
                                        AVOID CREATING DUST
                                  CANCER AND LUNG DISEASE HAZARD
                                BREATHING AIRBORNE ASBESTOS FIBERS
                                   IS HAZARDOUS TO YOUR HEALTH

         These labels are three (3) inches high by five’ (5) inches wide and conform to the requirement specified in
         29 CFR 1910.145 for danger labels or signs.

11.7.4   DOT Transportation Labels: In addition to the warning labels required by both OSHA and the EPA, the
         United States Department of Labor (DOT) requires a warning label on each bag of asbestos-containing
         materials that is transported away from the removal site. This label must read as follows:

                                         RQ HAZARDOUS SUBSTANCE
                                          SOLID, N.O.S. (ASBESTOS)
                                              ORM-E, NA-91S8

         The size of the DOT label must be approximately the same size; as the label required by OSHA.

11.7.5   Generator Labels: NESHAPS requires that each bag of asbestos-containing material that is to be
         transported off of the facility site, contain a visible label identifying the name of the generator (owner) and
         the location at which the waste was generated. This generator label must either be printed on the outside of
         the bag or it must be a separate label attached to the bag, or it can be a separate label that is inserted
         between the two poly bags if the outside bag is a clear bag that would allow the label to be read without
         opening the bag.
                                ASBESTOS ABATEMENT GUIDELINES                           . -~

       11.7.6   Secured Storage Facilities: Drums, bags and/or wrapped components of ACM that have been
                removed from the immediate work area and are being temporarily stored while awaiting
                transportation to the disposal site, must be stored in an enclosed and lockable storage area, truck or
                dumpster. These storage areas must
                 be locked when unattended. The enclosed storage areas must be free of debris and lined with 6-mil
                 poly sheeting to prevent contamination from leaking or spilled containers.

11.8   Small-Scale Short-Duration Removal Procedures

       Appendix G of the Standard provides a means by the Contractors and! or employers may be exempted from
       the requirements of establishing negative pressure enclosures and designating a competent person,
       paragraphs (b) and (e) (6) of the Standard, when performing a small-scale, short-duration renovation or
       maintenance activities. It must be noted however, that the use of this exemption is meant only for those jobs
       where the removal of asbestos-containing materials is not the primary goal of the job (e.g., valve repair,
       fastening conduit to a pipe insulated with ACM, nonrepetitive operations, etc.). It is not meant for a normal
       removal project or even for a series of small jobs which if preformed at one time, would be a big job.

       Several methods can be used to remove small amounts of asbestos-containing materials ‘—i during small-
       scale, short-duration renovation or maintenance tasks. These include the use of glove bags, the removal of
       an asbestos pie insulation and the construction of mini-enclosures.

       Although, small-scale, short-duration projects do not necessarily require all aspects of the Standard, a
       decontamination unit must be available at the site to handle emergency decontamination in the event of a
       spill.

       11.8.1   Glove Bags: Each Glove Bag may be used only once for removing three (3) lineal feet or less of
                friable asbestos-containing material from heating, ventilation, and air conditioning (HVAC) ducts,
                short piping runs, valves, joints, elbows, and other surfaces in an uncontained work area. The
                glove Bag application will be performed by a minimum of two (2) workers operating as a team to
                engage the bag, wet the asbestos-containing materials, remove the asbestos, apply the encapsulant,
                remove the tools, seal and remove the bag. This requirement to have at least two persons assigned
                to each Glove Bag must be complied with wherever feasible. In the unlikelihood the physical
                location of the removal site absolutely limits the number of workers doing the removal, the second
                worker must remain in the immediate vicinity to be available for assistance when needed. Sliding
                the Glove Bag along the pipe from one location to another in prohibited.

                The area to be worked on must be established as a regulated area with
                barrier type and appropriate warning signs. All employers within the
                immediate vicinity must have been notified of the abatement project.
                Appropriate respirators and protective clothing must be worn.
                                  ASBESTOS ABATEMENT GUIDELINES
12.0   DISPOSAL OF ASBESTO-CONTAINING MATERIALS

       Friable asbestos-containing waste material and debris, which is packaged in accordance with the provisions
       of this procedure, may be disposed of at any designated sanitary landfills when certain precautions are
       taken. These include notifying the appropriate Environmental Protection Agency regional office, and, where
       required, obtaining the necessary permits form appropriate state and/or local agencies.

       12.1   ACM Waste for Transport

                Unless otherwise required by the contract document, GAC             will not be required to use
                containerized waste disposal methods.

                Bagged asbestos-containing waste, which is ready for disposal, will not be stored in the open
                outside of the work area. These bags will either be left in a secured staging room, stored in a
                locked area designated by the Owner, or taken directly from the work area to a truck or dumpster
                which is closed and capable of being locked. Care must be exercised before and during transport to
                insure that no authorized persons can have access to the ACM waste material.

                Waste disposal bags that are not containerized will not be transported in open trucks. Double-
                bagged material may be transported in open trucks. Double-bagged material may be transported in
                open trucks if they are first loaded into container drums and the drums are then sealed. These
                drums must then be labeled with the same warning label as the waste disposal bags.

                Uncontaminated drums may be reused, but any drums that have been contaminated, must be
                treated as asbestos-containing wastes and disposed of in accordance with these Guidelines.

13.0    WORK AREA CLEANUP PROCEDURES

       This section details the cleaning and decontamination procedures to be followed during the final cleanup of
       the work area, including the decontamination of the air in the work area which has been contaminated by
       the elevated airborne asbestos fiber levels generated during the abatement activities.

        It includes the cleaning and decontamination of all surfaces (ceilings, walls, floors) of the work area and
        all furniture and equipment in the work area. In order to accomplish this, the cleaning and decontamination
        process will be conducted in a series of cleanings. These cleanings apply to that portion of the abatement
        project in which all visible asbestos-containing material has been removed form the substrate and the
        substrate has been brushed and wet wiped. During this entire cleaning process, the air filtering units must
        be maintained in continuous operation.
            ASBESTOS ABATEMENT GUIDELINES

         The area of insulation to be removed must be wet-wiped and sprayed with
         amended water or removal encapsulant prior to attaching the Negative-Air Bag

         The Glove Bag must be attached to the pie using approved methods. All of the
         necessary tools and equipment must be inserted into the bag prior to its being sealed.

         GAC must begin the removal process by using all of the normal engineering controls, including the use of
         amended water. During the removal process, personal air sampling must be conducted in accordance with
         air monitoring requirements of the Standard.

         When the removal of the insulation has been completed, the Glove Bag must be removed by approved
         method and then handled the same as any ACM waste. The removal process must be thorough and must
         include encapsulant being sprayed onto the ends of any remaining insulation and onto the open ends of the
         pipe.

         When the removal of the asbestos-containing material has been completed, all of the workers involved must
         undergo wither a complete decontamination process or be HEPA vacuumed and don a clean suit if using a
         remote decon.

11.8.2   Pipe Insulation (Inside the Work Area): Where pipe insulation is being removed within the work area, it
         should be sprayed with a mist of amended water or removal encapsulant and allowed to saturate the
         material to the substrate.

         Any wore or bands holding the preformed pipe insulation should then be cut, the jacket slit open at the
         seems, and the insulation removed and placed into waste disposal bags. Any residue left on the pipe or
         fittings should then be removed with a stiff bristle brush.




11.8.3   Mini-Enclosures: In some instances, such as removal of asbestos form a small
         ventilation system or from a short length of duct, a glove bag may not be large enough or of the proper
         shape to enclose the work area. In such cases, NIIRAM may elect to build a mini-enclosure around the area
         where small-scale, short-duration asbestos removal is to be performed.

         Such an enclosure must be constructed of the same materials as the large work area, but only one layer of
         poly is normally required. It can be constructed small enough to restrict entry to only one worker. The
         worker must wear an appropriate respirator and protective coveralls while in the mini-enclosure and the
         change room should be contiguous to the enclosure. This is necessary to allow the worker to vacuum off his
         protective coveralls and remove them before leaving the work area.
                                  ASBESTOS ABATEMENT GUIDELINES

13.1   Final Cleaning

       After the removal of all visible accumulations of asbestos material and debris, all surfaces in the work area
       and the decontamination units should be thoroughly cleaned with HEPA filtered vacuums or wet wiped.
       The decontamination units must also continuo to remain in operation.

       A second cleaning should now be conducted, again using HEPA filtered vacuums and/or wet wiping all
       surfaces. When this second cleaning has been completed, GAC should conduct a visual inspection of the
       work area and the decontamination units, to ensure that all areas are free of visible asbestos fibers. With the
       air filtering units and the decontamination units remaining in operation, all of the remaining poly should be
       stripped from the work area leaving only the critical barrier intact.

       At the time of the second cleaning, all remaining tools and equipment remaining in the work area and the
       decontamination units should be decontaminated by HEPA by vacuuming and/or wet wiping and then
       removed form the area. Once this is completed, the area is now ready to be visually inspected by the
       Owner, the Owner’s representative, or a representative of the independent air-monitoring firm. This
       individual should be identified in the contract document.

       If the results of the inspection are satisfactory, the individual conducting the inspection —~ should release
       the work area for encapsulation. This involves applying a sealant to the substrate and all of the remaining
       poly sheeting to “lock down” any tiny visible fibers which might remain. The mist, which occurs during
       application of the encapsulant, helps in settling and sticking down the fibers that are still airborne. And
       adequate time period should be established to allow the sealant t dry before conducting additional air
       sampling.

       Special attention must be paid to the Material Data Sheet (MSDS) of the encapsulant to be used, since the
       nature of some encapsulants may effect the requirements of respiratory protection. Vapors that are given
       off during the application of some encapsulants must be taken into account when selecting respiratory
       equipment if other that supplied-air respirators arc used.

       Air monitoring of the work area in the decontamination units should now be conducted to determine the
       fiber count in these areas. Unless otherwise specified in the contract document, this very important phase
       of the air sampling will also be conducted by the independent air-monitoring firm retained by GAC
       throughout the project

       If the results of this air sampling show a count of 0.01 or less fibers per cubic centimeter of air, the work
         area and decontamination units are ready for closeout. If however, there are still sufficient asbestos fibers
         airborne in the containment area to require additional cleanings, N7LR.AM may elect to perform an
         aggressive cleaning. In any case, GAC will continue to perform cleaning operations within the work area
         and the decontamination units an acceptable level of decontamination, as specified in the contract
         documentation, is obtained.
                                      ASBESTOS ABATEMENT GUIDELINES

       13.1.1      Aggressive Cleaning: Aggressive cleaning can be performed by blowing all
                   surfaces with a small motorized blower, such as a Leaf Blower, starting at the work area air
                   inlet(s), if any, and proceeding methodically toward the air filtering unit(s). Care must be taken to
                   proceed at a pace that is slow enough to allow the general air movement in the room to keep the
                   fiber “cloud” ahead of the blowing activity, so flint fibers are not redeposited on cleaned surfaces.

               This type of induced air movement will tend to “capture” all of the
               remaining airborne fibers and trap them in the air filtering units filter
               media, where they can be permanently removed.

        13.2      Removal of Temporary Enclosures

                   Upon acceptance of the air monitoring results, GAC will now begin dismantling operations of the
                   remaining work area, decontamination units and critical barriers. Although the area has been
                   tested “clean”, all debris from the removal of these areas will be packaged in disposal bags or
                   wrapped and sealed in poly for disposal as contaminated waste.

14.0    AIR MONITORING

        This section describes the air monitoring carried out by GAC to ensure the protection of asbestos
        abatement workers and to verify that the building beyond the work area remains uncontaminated.

        Unless the contract document specifies that air-monitoring services are to be provided by the Owner, GAC
        will engage the services of a competent, independent air-monitoring firm to perform sufficient air sampling
        to accurately determine the airborne concentrations of asbestos fibers to which the asbestos workers maybe
        exposed.

        The air-monitoring firm selected by NLRAM will have all of the professional qualifications and
        certifications necessary to collect air samples, conduct OSHA required analysis, provide timely results and
        implement specific quality control procedures as set forth in Appendix A of the Asbestos Standard, 29 CFR
        1926.58 and Section —9-3 Air Monitoring Guidelines of the Safety Program. All work performed by the
        selected company must be in accordance with this mandatory Appendix.

        14.1      Exception to Monitoring

                   The exception to the requirement for conducting daily monitoring that is representative of the
                   exposure of each employee in the work area, is when all workers in the work area are equipped
                   with supplied-air respirators operated I the positive pressure mode.

        14.2      Termination of Monitoring

                  Termination of daily air monitoring will only be in compliance with the requirements of Section 9-
                  3 Air Monitoring Guidelines of the Safety Program.
                                  ASBESTOS ABATEMENT GUIDELINES

       14.3   Employee Notification

              Immediately upon receipt of the air monitoring results, GAC will either post the results at the job
              site or will mail a copy of the results to the employees involved. When results are received after the
              completion of the job, or after the employees who are involved in the sampling have left the job
              site, copies of the results will be mailed directly to the employee as soon as possible.

       14.4 Observation of Monitoring

               GAC will provide affected employees, of their designated representative, an opportunity to
               observe the monitoring of employee exposure within the work area. When observation of these
               monitoring requires entry into the work area, the observer will be required to comply with all of
               GAC ’s safety procedures for entry into the work area. This included such procedures as a medical
               examination, respirator fit testing, respirator and asbestos training, the use of protective coveralls,
               etc.

15.0   DEMOBILIZATION

       The air filtering units should be turned off, sealed in poly and transported to the next project. All debris,
       used cleaning material, unsalvageable materials used for the enclosures and any other remaining materials
       should be disposed of as contaminated waste. All sealed and labeled bags “~ containing contaminated
       waste will then be removed from the Owner’s property by approved transport methods.

       All contaminated waste that has been removed from the project during the demobilization operation will be
       disposed of at the selected waste disposal site. The transport vehicles will then be decontaminated and the
       protective clothing worn by the disposal workers will be included in the disposal process

16.0   FINAL DOCUMENTATION

       Unless project documentation has been submitted to the Owner, or the Owner’s representative on a timely
       basis throughout the length of the project, or unless otherwise stipulated by the contract document, final
       documentation will be submitted to the Owner, or the Owner’s Representative for review acceptance and
       permanent file.
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